“The legal feasibility of extending the Reparations Loan approach towards such assets has not been assessed in detail,” the document continued. “Such an assessment would need to take place before taking a decision on further steps.”

The document outlines the “design principles” for the Ukraine Reparations Loan initiative that will be up for debate ahead of next week’s EU summit in Brussels.

EU leaders are expected to have a broad discussion on the initiative and to call on the Commission to present a proposal for the loan. EU officials expect the bill to arrive quickly, and to serve as a platform for further talks on the financial engineering needed to make it work.

Finance ministers will discuss the bill when they next meet in November.

Guarantees and spending targets

Other design principles include national guarantees for the loan, a key demand from Belgium, which fears Moscow could send an army of lawyers its way to retrieve the sanctioned cash.

“A solid guarantee and liquidity structure should be put in place to ensure that the EU can always honour its obligations to Euroclear,” the document continued. “For that purpose, it is suggested to build a system of bilateral guarantees from Member States to the Union.”